In Cipollone v. Liggett Group, Inc., 505 U.S. 504 (1992), in the context of a preemption provision in the Public Health Cigarette Smoking Act of 1969 (1969 Cigarette Act), the Supreme Court concluded that state failure to warn claims are preempted to the extent they require a showing that the defendants' advertising or promotions should have included additional or clearer warnings. ( Cipollone, supra, at p. 524.) However, the court found that preemption did not apply to claims that rely solely on the defendants' testing or research practices or other actions unrelated to advertising or promotion. (Ibid.) Further, breach of express warranty claims based on representations voluntarily made are not preempted by the 1969 Cigarette Act. (Cipollone, at pp. 525-526.) The United States Supreme Court explained that state law is not preempted by federal law unless it is the "clear and manifest purpose of Congress" to effect preemption, a purpose that can be demonstrated by the express language of the federal enactment or its structure and purpose, or by a direct conflict between the terms of the federal and state enactments, or by a showing that federal law occupies the field so completely as to justify the inference that state legislation addressing that subject is precluded. 505 U.S. at 516. (quoting Rice v. Santa Fe Elevator Corp., 331 U.S. 218 (1947)). As the Court have previously noted, the United States Supreme Court has held that there is a clear and manifest purpose by Congress that the controlling provisions of the SGLIA prevail over and displace inconsistent state law. Ridgway v. Ridgway, 454 U.S. 46, 70 (1981).